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      Other news in brief

      Bill to bring in salary sacrifice pension changes published

      From April 2029, pension contributions made through salary sacrifice above an annual cap of £2,000 will be subject to both employee and employer NICs. The primary legislation to implement this measure was published on 4 December 2025. A second reading of the National Insurance Contributions (Employer Pensions Contributions) Bill will take place on 17 December 2025, the day before Parliament is due to rise for Christmas. NIC Regulations will be used to formally set the £2,000 threshold in due course.

      'Help with Investment Zones' HMRC guidance published

      On 27 November 2025, HMRC published the latest in their Guidelines for Compliance (GfC) series: Help with Investment Zones (GfC15). This guidance is aimed at businesses that are operating, or intending to operate, within an Investment Zone. It outlines the tax reliefs available, details how to quality for them and highlights common errors businesses make.

      Changes to restitution interest rules in Part 8C of the Corporation Tax Act 2010

      On 1 December 2025, The Corporation Tax Act 2010 (Part 8C) (Amendment) Regulations 2025 were published alongside an accompanying HMRC policy paper. The background to this is that Part 8C of the Corporation Tax Act 2010 was introduced to levy a 45 percent tax on certain payments of court awarded interest where the effective rate of interest was significantly higher than the simple interest that would be given under the Taxes Acts. The intention was to tax the windfall generated by these high rates of interest/compound interest. However, it was subsequently identified that on a plain reading of the legislation, it would apply to all payments of interest awarded by the High Court in the litigation, not just the higher amounts it was targeting. The new regulations clarify that Part 8C does not apply to claimants who are entitled to awards of simple interest at a rate which is equivalent to, or lower than, a statutory rate of repayment interest available under the Taxes Acts. The change is only expected to impact a small number of corporate claimants.

      HM Treasury revises target implementation date to implement Pillar One, replacing the UK Digital Services Tax, from 2024 to 2027

      In a recent ‘Treasury Minutes’ publication (pages 56 and 57), the Government commented on its plans to implement Pillar One and remove the Digital Services Tax. It said “it is not possible to provide a precise timeline” but due to delays in reaching international agreement the Government has revised its target implementation date from 2024 to 2027.

      Acquisition of country estate ruled as mixed use transaction for SDLT

      In Goudman-Peachey v HMRC [2025], the First-tier Tribunal ruled that the acquisition of Woodmancote Place - a substantial 150-acre country estate - should be treated as a mixed-use transaction for stamp duty land tax (SDLT) purposes, rather than wholly residential. The decision reflects the clear evidence of non-residential elements, including commercial deer farming and large-scale sheep grazing. The fact that HMRC decided to pursue this case, despite these facts, highlights their willingness to test the boundaries of SDLT legislation following significant success at Tribunal on a number of more marginal cases.

      Update on new tax treaties with Peru, Romania, Andorra, and Portugal

      Parliament debated and agreed draft regulations to ratify new double tax treaties with Peru, Romania, Andorra, and Portugal on 1 December 2025. Dan Tomlinson, the Exchequer Secretary to the Treasury said during the debate in relation to the ratification position in the treaty partner jurisdictions “Romania has ratified this already and Peru, Andorra and Portugal are expected to do so by the end of the year”.

      UK announces intention to implement the OECD’s framework for the automatic exchange of information on immovable property

      As part of the output from the recent G20 Finance Ministers and Central Bank Governors meeting, the OECD published its new framework for the automatic exchange of information on immovable property (real estate). Following that, on 4 December 2025, HM Treasury published a Joint Statement confirming that the UK and 24 other jurisdictions have announced their aim to implement this new transparency framework. NB The OECD then added one further jurisdiction, Indonesia, when it published its own version of the joint statement. The stated aim is to implement the framework by 2029 or 2030.

      KPMG UK's December 2025 Economic Outlook published

      KPMG UK's economics team have published their latest forecast for the UK economy in 2026 and 2027. It looks at growth prospects, consumer spending, inflation, interest rates, business investment, the housing market, planning reform, the labour market and public finances.

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